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Foreign hybrids presentation

Member Price: Free
Non Member Price: $15.00

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Published on 19 Sep 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This presentation covers:

  • why the rules were needed
  • were the problems fixed
  • what was delivered
  • what new problems have been created.

Author profile

Neil Billyard CTA
Neil is a Partner in International Corporate Tax at KPMG. Neil has over 22 years corporate tax experience and specialises in foreign merger and acquisition activities of Australian multi-nationals, cross-border funding, the repatriation of profits and other related structuring. He is actively involved in working with Treasury and government on a variety of international tax reform issues, including assisting with policy development and drafting of legislation. He has lectured the Master of Laws/Tax course at the University of Sydney and is a regular presenter for The Tax Institute. - Current at 01 February 2011
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This was presented at International Tax Masterclass .

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Foreign hybrid entity rules - close but not close enough

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Changes to the foreign tax credit regime - a high level summary

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Thin capitalisation - a selection of issues

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Withholding tax considerations

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Substantial equipment

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Strategies for managing offshore taxation obligations and risks

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The new withholding obligations

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